What About Switzerland? EUDR Impact on One of the Biggest Non-EU Players in the Coffee Game
CoffeeNetwork (New York) – The European Union Deforestation Regulation (EUDR) has been plagued with uncertainties and unknowns since its conception. The biggest question mark today is when will the EUDR go into effect following numerous attempts to have it delayed.
On December 3rd, negotiators from EU Member States and the European Parliament reached a provisional agreement to postpone the law’s application by one year. However, this still requires formal endorsement by the European Parliament (ENVI and Plenary) and the Council during the Plenary Session scheduled for December 17-19 before proceeding through the formal adoption procedure. If approved as expected, the changes can still take effect before the regulation's current application date of December 30, 2024.
The Swiss Coffee Trade Association (SCTA), working in close collaboration with the European Coffee Federation on all EUDR matters, emphasizes that this provisional agreement must be confirmed and formally endorsed by both the Council and the European Parliament before it can be considered definitive.
The proposed delay could benefit all operators both within and outside of the EU by allowing the use of stock that arrived during or before the transition period, while also providing additional time to continue crucial efforts in supporting producers to achieve EUDR compliance across some of the more complex supply chains.
While a delay in implementation is looking increasingly likely, there are still many ambiguous details in the legislation that makes it difficult for the trade to know exactly how to interpret certain clauses effectively. For Switzerland and other non-EU countries, such as the UK, additional questions arise regarding the implementation of EUDR responsibilities for non-EU operators involved in importing from or exporting to EU countries after the regulation's application date.
As a key player in the global coffee market, will Switzerland have to jump through additional hurdles, or will Swiss traders be able to continue trading with the EU the same way as they did before EUDR?
Switzerland, as a non-EU country, technically could still import, process and consume coffee that does not comply with EUDR. Coffee could enter through any EU port, be stored in a bonded warehouse under customs control, and then transported to Switzerland for customs clearance. Since such coffee would not be released or placed onto the EU market, it would not be subject to EUDR compliance requirements.
However, about half of the green coffee that Switzerland imports is being exported to the EU. “For Swiss operators, aligning with EUDR requirements is not just about compliance but about maintaining seamless trade with the EU market,” says Dr Krisztina Szalai, Secretary General of the SCTA.
Swiss Coffee Market
Landlocked Switzerland receives most of its coffee through Basel, the first stop for the Rhine River barges, Bert Koers, Ambassador to Swiss-based Blaser Trading, Board Member of the SCTA and President of Procafe tells CoffeeNetwork. “Due to the different situation the last 20 years, manufacturers and importers are taking advantage of certain stockholding companies offering landing of green coffee,” he explained. “Why not take your coffee to Hamburg or Bremen and store it there and then let the forwarding agent do the blending?” The coffee is then sent to Switzerland via rail or being transported in bulk containers by trucks.
Bigger retailers in the south of the country use the Genoa port. “This is easier transit for them into Switzerland and saves them on inland freight costs as they are going through the Mediterranean and not through Northern Europe,” Koers said.
The paperwork required to bring coffee into Switzerland was already substantial, but the EUDR has significantly increased the administrative burden.
Brazil accounts for the majority of green coffee imported into Switzerland, followed by Vietnam. According to data provided by Koers, Switzerland imported 186,000 tons of green coffee in 2023, over 50% of which is re-exported as finished products. Most of that coffee is exported in capsules. The figures from 2024 are expected to show a slight increase in domestic consumption, despite staggeringly high prices. It is not uncommon for the Swiss to pay more than $5.20 on average for a cup of coffee at a café. The coffee capsule remains the preferred method of in-home- and office consumption, with the costs ranging from $95-105/kilo. Around 70% of coffee imports fall into some form of sustainability criteria system, including certified products, Koers tells CoffeeNetwork.
Data Platform Disparity
The European Commission plans to implement the EUDR with the help of The Deforestation Due Diligence Registry, a specialized online tool that streamlines the creation of due diligence statements within the coffee supply chain. According to the website, “the Registry allows operators, traders and their representatives to make electronic Due Diligence Statements and submit them to the relevant authorities to show that their products do not cause deforestation…” to prove EUDR compliance.
In the latest round of negotiations, the European Commission has also committed to operationalizing data platforms and risk classification systems at least six months before the regulation takes effect.
Szalai emphasizes the value of “diversity” within the Switzerland’s coffee trade, a sector deeply embedded in the country’s rich history and global standing as a commodity trading hub. Switzerland’s geostrategic location, combined with its expertise in trade finance and insurance, has established it as a leading global hub for raw materials and green coffee trading.
While Switzerland is home to one of the world’s largest coffee roaster and manufacturers, as well as numerous smaller roasters and coffee shops, it is perhaps best recognized as a central hub for a dynamic and vibrant community of green coffee traders. These traders include large international trade houses with offices across Europe and beyond, as well as mid-sized and smaller traders operating exclusively within Switzerland. Together, they manage 55% of global coffee exports, equating to 65 million bags annually.
Despite this central role, the EUDR poses unique challenges for Swiss coffee traders. Those without EU-based offices face additional complexities in their operations, while even traders with an EU presence must navigate considerable bureaucratic burdens. In an increasingly interconnected and regulated world, Switzerland’s coffee sector continues to play a pivotal role in ensuring global market stability and security of supply, with green coffee traders acting as key facilitators of sustainable trade, fostering strong relationships across the supply chain, and driving innovation to meet evolving global demands.
“At SCTA, we are actively collecting feedback from our members—both large and small—on their most pressing questions and concerns about EUDR,” Szalai says. “This includes issues such as the level of access to the EUDR Information System and the implications of re-imported goods moving from the EU to Switzerland and back to the EU after the transition period.” The SCTA is working closely with the European Coffee Federation and the Swiss Federal Government to ensure these challenges are effectively communicated and that SCTA members receive the necessary clarifications to navigate these regulatory requirements. “This collaborative effort aims to reduce uncertainty, streamline processes, and support all traders in achieving compliance,” she says.
According to Szalai, the level of access to the EUDR Information System is currently a significant concern for Switzerland, in addition to the existing challenges faced by other operators across Europe. She noted that some producing countries in regions such as East Africa, Southeast Asia, and Central America may struggle with the time and resources required for compliance. "The supply chain is not always a simple, linear structure," she explained, highlighting the difficulties in achieving full traceability in certain contexts despite the considerable efforts and ongoing investments made by the trade.
Increasing complexity
Switzerland, both a major importer and exporter of coffee, has to navigate an increasingly complex framework of new regulations which apply to its supply chain operators both directly and indirectly.
“What happens with re-imports of coffee after the transition period, particularly for products that initially entered the EU without requiring a DDS?” asks Szalai. “The answer depends on several factors, such as whether the coffee was placed on the EU market during the transition period, whether it underwent processing after export, or whether its EUDR-compliant status was maintained while outside the EU.” She highlights the need for clarity on acceptable documentation to prove compliance in such cases. “These questions reflect the intricate nature of EUDR implementation and the pressing need for detailed and context-specific guidance to address the complexity of global and European coffee supply chains,” she notes.
Under the European Union Deforestation Regulation (EUDR), coffee must comply with specific due diligence requirements upon being placed on the EU market, which typically occurs at the point of customs clearance. Coffee arriving at bonded warehouses across Europe generally gets customs cleared only once a buyer is found. This practice is not about avoiding compliance but is instead a cost-driven decision, as customs clearing coffee into the market before securing a buyer adds additional expenses for traders while the coffee remains in storage.
As Szalai explains, while some larger traders have affiliated entities within the EU to manage purchasing and customs clearance of coffee, this practice is less common than it might initially seem. In the few instances where EU-affiliated entities are used, this approach can facilitate compliance but adds significant administrative complexity, as Swiss and EU entities of the same company must coordinate ownership transfers and internal transactions. In Europe—unlike in the USA—import processes are often managed through collaboration across the supply chain, with both traders and roasters playing vital roles in meeting regulatory requirements. Ensuring compliance and maintaining efficiency under evolving regulations is a shared responsibility, with traders and roasters working together to drive collaboration and develop effective compliance solutions.
A SDR On the Horizon?
The Swiss Government has not yet established its own deforestation regulation, though discussions on the topic are ongoing.
The Centre for Development and Environment at the University of Bern has been closely examining Switzerland's role and impact under the EUDR. According to their research, "Switzerland is analyzing the EUDR and has not yet decided whether to enshrine the same rules in Swiss law." Previous discussions at the Swiss Federal Council have resulted in a decision against adaptation, with the government currently exploring alternative support measures for affected companies. However, some suggest that this decision may need reconsideration in the future.
"Green coffee traders are the backbone of the global coffee supply chain, securing supply, managing risks, and overcoming logistical challenges in an increasingly complex environment," says Szalai. "They not only ensure the smooth movement of coffee but also play a critical role in helping producers comply with evolving regulatory demands and advancing sustainability across the supply chain. Switzerland, as the global hub for green coffee trade, must safeguard the competitiveness of its traders while creating a regulatory environment that supports a thriving and sustainable coffee trade” adds Szalai.
Alexis Rubinstein
